- 14 - less, sec. 6673(a)(1)(B). In Pierson v. Commissioner, 115 T.C. 576, 581 (2000), we issued an unequivocal warning to taxpayers concerning the imposi- tion of a penalty under section 6673(a) on those taxpayers who abuse the protections afforded by sections 6320 and 6330 by instituting or maintaining actions under those sections primarily for delay or by taking frivolous or groundless positions in such actions. In the petition and in petitioner’s motion and his response to respondent’s motion, petitioner is raising, we believe primarily for delay, arguments and contentions that we have previously rejected, thereby causing the Court to waste its limited resources.12 We shall impose a penalty on petitioner pursuant to section 6673(a)(1) in the amount of $10,000. We have considered all of the arguments and contentions that petitioner advances in petitioner’s motion and petitioner’s response to respondent’s motion, which are not discussed herein, and we find them to be without merit and/or irrelevant. On the record before us, we shall deny petitioner’s motion, and we shall grant respondent’s motion. 12Petitioner is well aware of the Court’s views regarding the allegations of error that he raised in the petition. They are essentially the same allegations that he raised as the representative for the taxpayer in Davis v. Commissioner, supra, and for the taxpayer in Wylie v. Commissioner, supra.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
Last modified: May 25, 2011